FinCEN Delays AML/CFT Program, SAR Filing Requirements by 2 Years

On December 31, 2025, the US Division of the Treasury’s Monetary Crimes Enforcement Community (FinCEN) finalized a two‑yr delay of the efficient date for the anti-money laundering/counter-financing of terrorism (AML/CFT) program and suspicious exercise reporting (SAR) submitting necessities relevant to sure funding advisers. FinCEN has pushed the compliance date from January 1, 2026, to January 1, 2028.

Background

The 2024 adviser AML/CFT rule outlined sure registered funding advisers and exempt reporting advisers as “monetary establishments” beneath the Financial institution Secrecy Act, subjecting them to AML/CFT program necessities, SAR reporting, and associated recordkeeping (Adviser AML Rule). For extra details about the Adviser AML Rule, see our prior publication.

Takeaways

• FinCEN famous that delaying the efficient date will present FinCEN with extra time to evaluate the Adviser AML Rule and guarantee efficient tailoring to the totally different enterprise fashions of advisers.
• Many commenters on the Adviser AML Rule urged coordination with associated however unfinished rulemakings (particularly, the proposed rule establishing customer identification program (CIP) rule requirements for investment advisers) and advisable aligning timelines.
• In consequence, the Adviser AML Rule should still endure refining by FinCEN. We count on coordination of the implementation timeline to coincide with the finalization of the proposed CIP rule relevant to funding advisers.